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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Tuesday, November 14, 2023

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$197.00
CPE
ALL

This presentation will review the special compliance requirements for foreign partners and members of U.S. and foreign partnerships that have U.S. filing and withholding obligations. Our veteran international tax practitioner will review circumstances when the newest withholding rules apply, exceptions to the withholding rules, and the interaction of these rules with FIRPTA provisions surrounding the sale of partnership interests.

Faculty

Ragini Subramanian
Senior Manager
Eisner Advisory Group, LLC

Ms. Subramanian is a Tax Senior Manager in the Private Client Services Group. With over 10 years of tax experience, she provides comprehensive tax, compensation, and financial planning services including international and domestic tax planning for high net worth individuals and closely held entities. Ms. Subramanian has expertise in FIRPTA compliance issues related to holding of U.S. real property interest, expatriation and inpatriation planning, foreign information reporting requirements for individuals and entities, including FBAR, and Forms 8938, 5471, 8865, 926, 3520, 3520-A, 8858.

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Description

Additional rules apply when a foreign person utilizes a partnership to invest in the United States. The foreign partner in the partnership and the partnership must navigate through a complex set of rules that vary depending on the nature of the investment and whether or not the investment is in U.S. real property.

When the investment is in U.S. real estate, the interaction between FIRPTA regulations and other withholding rules governs the relationship of partners with the partnership as well as the partnership's obligations to the IRS.

These rules are sprinkled across various IRC Sections from 1441 to 1446. The recent changes to Section 1446 added another layer of complexity to these already complicated requirements. Now, after changes in 2019, 2020, and 2021, a foreign partner's sale of partnership interest is subject to special withholding rules unless an exception applies.

Listen as our experienced foreign flow-through expert explores the complex rules associated with foreign partners investing in partnerships and outlines the governing rules under Section 1446(f) covering a foreign partner's sale of a partnership interest.

Outline

  1. Introduction
  2. Rules related to the taxation of foreign persons investing in the U.S.
  3. Taxation of foreign partners engaged in a U.S. trade or business
  4. Taxation of foreign partners not engaged in a U.S. trade or business
  5. Taxation of a foreign partner in a partnership investing in U.S. real property
  6. Withholding requirements
  7. Examples

Benefits

The panelist will cover these and other critical issues:

  • When is a partnership required to withhold taxes?
  • What rules apply if the partnership is considered engaged in a U.S. trade or business?
  • What rules apply if the partnership is not considered engaged in a U.S. trade or business?
  • What rules apply if the partnership is not investing in U.S. real property as opposed to in U.S. real property

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify partnership withholding requirements for foreign partners
  • Determine how to calculate effectively connected income and withholding obligations under Section 1446(f)
  • Decide how FIRPTA provisions apply to the sale of partnership interests
  • Ascertain differences in withholding requirements for partnerships with U.S. real property investments

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).